Required Antiterrorism Provisions Were Not Included in Some Subawards – Executive Order 13224 on Terrorism Financing

U.S. law prohibits transactions with individuals and organizations associated with terrorism. Consequently, grants, and cooperative agreements with implementing partners contain the following section, titled “Executive Order 13224 on Terrorism Financing”:

U.S. Executive Orders and U.S. law prohibits transactions with, and the provision of resources and support to, individuals and organizations associated with terrorism. It is the responsibility of the contractor/recipient to ensure compliance with this Executive Order and applicable laws. This provision must be included in all subcontracts/subawards issued under contract.

Contract provisions such as Executive Order 13224 heighten public awareness of individuals and entities linked to terrorism, and promote due diligence by private sector entities to avoid associations with terrorists. Without ongoing communication about specific antiterrorism requirements and periodic verification of procedures and compliance, [one] has little assurance that programs do not inadvertently support entities or individuals associated with terrorism.

General Recommendations

Require that implementing partners verify and certify that all subawards include the required provision related to Executive Order 13224.

Source: AUDIT REPORT NO. 4-663-10-003-P MARCH 30, 2010

The recommendations are derived from audit reports of the Office of the Inspector General. The source refers to the audit report, which is available on this site as part of the Audit Database Project: an educational tool for compliance with USAID regulations. Please see the disclaimer of this site before using recommendations.